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GROUP PRIVACY POLICY

RENTCLEVA PTY LTD ACN 163 636 137 (RENTCLEVA)
AND
FOREX 1 PTY LTD ACN 133 409 882 AS TRUSTEE FOR THE TRADING RENTAL TRUST T/AS RENTORILLA (RENTORILLA)
    • Introduction
      1. Rentcleva offers customers access to technology in home entertainment and white goods on a rental basis. Rentorilla collects payments and information from Rentcleva’s customers as Rentcleva’s agent and provides other services to Rentcleva. Rentcleva’s and Rentorilla’s services are collectively described in this policy as the Services. In this policy, “we” refers to Rentcleva and Rentorilla.
      2. In the course of our business, there are circumstances where we collect personal information. This privacy policy has been developed to ensure that this information is handled appropriately.
      3. We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs) which set out the way in which personal information must be treated.
      4. This privacy policy also incorporates our policy on managing credit information (see particularly section 8 onwards).
      5. Who does the privacy policy apply to?
      6. This policy applies to any person for whom we currently hold, or may in the future collect, personal information.
      7. Generally, we only collect personal information from customers, subcontractors and agents who perform services on our behalf, and from prospective employees.
      8. What information does the privacy policy apply to?
      9. This policy applies to personal information. In broad terms, 'personal information' is information or opinions relating to a particular individual who can be identified.
      10. Information is not personal information where the information cannot be linked to an identifiable individual.
    • How do we manage the personal information we collect?
      1. We manage the personal information we collect in numerous ways, such as by:
        • implementing procedures for identifying and managing privacy risks;
        • implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
        • providing staff with training on privacy issues;
        • implementing mechanisms to ensure any agents or contractors who deal with us comply with the APPs;
        • implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints;
        • appointing a privacy officer within the business to monitor privacy compliance; and
        • allowing individuals the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances.
      2. We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
      3. In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us (for example, when making a general enquiry with us). However, if you would like to order a product or service from us, we will need your personal information in most instances in order to supply you with the product or service.
    • What kinds of information do we collect and hold?
      1. Personal Information
      2. We may collect and hold personal information about you, which may include:
        • name and contact information;
        • age and date of birth;
        • gender;
        • employment arrangements and history;
        • driver’s licence number;
        • financial information;
        • credit information (see section 8 below);
        • banking details;
        • marketing preferences;
        • associated businesses and the details of those businesses;
        • information in publicly available company records about you; and
        • any other personal information required to provide the product or service to you.
      3. Sensitive Information
      4. We generally do not collect sensitive information about individuals.
    • How do we collect personal information?
      1. Our usual approach to collecting personal information is to collect it directly from you on application forms, through our website, by email and physical correspondence with you and telephone conversations with you.
      2. We may also collect personal information in other ways, which may include:
        • from our related entities, including Rentorilla and Rentcleva;
        • from our subcontractors and agents;
        • through our website;
        • through referrals from individuals or other entities;
        • from credit reference and credit checking agencies, and financial institutions;
        • from third party providers and suppliers;
        • from employers, colleagues, associates or relatives of yours (where necessary, we will make reasonable enquiries to verify the information);
        • from government bodies (such as Centrelink and the Australian Taxation Office);
        • through marketing events and programs; and
        • from any other consultants and business contacts we engage with from time to time.
      3. In some circumstances we may be provided with personal information about an individual by somebody else, for example a referral from another person. We will take reasonable steps to inform the individual about whom we hold the personal information and the purpose for which we hold the personal information.
      4. If the personal information we request is not provided, we may not be able to process an individual’s application, or provide individuals with the benefit of our services, or meet an individual’s needs appropriately.
    • How do we hold personal information?
      1. We generally hold personal information:
        • physically at our premises; and
        • electronically:
        • on secure online servers; and
        • on our website.
      2. We secure the personal information we hold in numerous ways, including:
        • using security systems to access areas that contain personal information;
        • using secure servers to store personal information;
        • using unique usernames, passwords and other protections on electronic systems that can access personal information;
        • holding certain sensitive documents securely; and
        • regularly destroying documents that are no longer needed subject to legal obligations for record keeping.
    • Why do we collect, hold, use or discloase personal information?
      1. We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. Generally, the primary purpose for which we collect personal information is to conduct our business and to provide you with products and services.
      2. In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.
      3. Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection. For example, we may collect and use your personal information:
        • to enter into contracts with sub-contractors to conduct our business;
        • to assess applications;
        • to collect payments that are overdue;
        • to administer an individual’s account;
        • to keep record of transactions to assist in future enquiries and enhance our customer relationship with you;
        • for delivery purposes;
        • to provide you with updates and alerts that are relevant to you or your business;
        • to send you special offers and promotional material;
        • to invite you to events; and
        • to comply with our legal obligations.
      4. We may disclose personal information to:
        • any person or organisation named by an individual in any application documents;
        • consultants we engage to assist you and to assist our business;
        • organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
        • organisations involved in managing our corporate risk and funding functions (e.g. securitisation);
        • our suppliers and partners;
        • government bodies (such as Centrelink and the Australian Taxation Office);
        • business support service providers (for example our software suppliers, debt collection agencies, data backup provider, law and accounting firms, compliance consultants or other consultants);
        • any other third party we deem necessary in connection with providing you with the products or services; and
        • Rentorilla, Rentcleva and any other of our related entities.
      5. Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act
    • Will we disclose personal information outside Australia?
      1. Other than limited personal information that we disclose to our lead developer located in the United States of America, we do not disclose personal information outside of Australia.
    • How do we manage your credit information?
      1. What kinds of credit information may we collect?
      2. In the course of providing products or services to you, we may collect and hold the following kinds of credit information:
        • your identification information;
        • information about any credit that has been provided to you;
        • your repayment history;
        • information about your overdue payments;
        • if terms and conditions of your credit arrangements are varied;
        • if any court proceedings have been initiated against you in relation to your credit activities;
        • information about any bankruptcy or debt agreements involving you;
        • any publicly available information about your credit worthiness; and
        • any information about you where you may have fraudulently or otherwise committed a serious credit infringement.
      3. In some circumstances, we may collect credit information and personal information from credit reporting bodies (e.g. Veda). In particular, we may run credit checks on you or your business. The kinds of information we collect may include any of those kinds of information outlined in sections 3.1 and 8.1 of this policy.
      4. We may also collect personal information which may affect your credit worthiness from other credit providers, who have collected that information from a credit reporting body. The kinds of personal information we collect may include any of those kinds of personal information outlined in section 3.1 of this policy.
      5. How and when do we collect credit information?
      6. In most cases, we will only collect credit information about you if you disclose it to us.
      7. Other sources we may collect credit information from include:
        • credit reporting bodies;
        • banks and other credit providers;
        • your suppliers or other businesses you deal with;
        • other individuals and entities via referrals;
        • government bodies; and
        • suppliers and other creditors.
      8. How do we store and hold the credit information?
      9. We store and hold credit information in the same manner as outlined in section 5 of this policy.
      10. Why do we collect the credit information?
      11. Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the requested product or service.
      12. We may also collect the credit information:
        • to process payments;
        • to notify a credit provider if an individual is in default;
        • to exchange personal information with other credit providers as to the status of an individual's account;
        • to assess an individual's credit worthiness and eligibility for credit;
        • to allow a credit reporting agency to create a file about an individual; and
        • for any other purpose that we consider necessary to best provide you with the applicable service or product.
      13. Overseas disclosure of the credit information
      14. Other than limited credit information that we disclose to our lead developer located in the United States of America, we will not disclose your credit information to entities without an Australian link unless you expressly request or authorise us to.
      15. How can I access my credit information, correct errors or make a complaint?
      16. You can access and correct your credit information, or complain if you believe there has been a breach of your privacy in the same manner as set out in section 9 of this policy.
    • How do you make complaints and access and correct your personal information or credit information?
      1. It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes. Access to information and correcting personal information
      2. Access to information and correcting personal information
      3. You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
      4. Subject to section 9.4, we will grant you access to your personal information as soon as possible.
      5. In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
      6. We may deny access to personal information if:
        • the request is unreasonable;
        • providing access would have an unreasonable impact on the privacy of another person;
        • providing access would pose a serious and imminent threat to the life or health of any person; or
        • there are other legal grounds to deny the request.
      7. We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
      8. If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
      9. Complaints
      10. If you wish to complain about an alleged privacy breach, you must follow the following process:
        • The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
        • In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
      11. Who to contact
      12. A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to hi@rentcleva.com.au
    • Changes to the policy
      1. We may update, modify or remove this policy at any time without prior notice. Any changes to the privacy policy will be published on our website.
      2. This policy is effective September 2016. If you have any comments on the policy, please use the contact details in section 9.9 of this policy.